A Lead Auditor on Electronic Recycler Non-Conformances

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top 10 non-conformances by electronic recyclers

by Ronald Lepore 

A former RQO auditor, Ronald has been instrumental in the development of multi-site Canadian electronics recycling operations, including shredding and manual teardown. He has years of experience implementing R2/RIOS, ISO 14001, ISO 9001 and OHSAS 18001 Standards.


Free Educational Webinar

Electronic Recycling Best Practices

Register here

Tuesday, February 20, 2018
Expert: Ronald Lepore


As a lead auditor for ISO 14001, RQP, R2/RIOS, OHSAS 18001, and ISO 9001, I have audited a vast number of electronic recyclers. To help you pass your next audit with flying colours, I am happy to share what auditors look for during an audit and issues that cause non-conformances.


What You Should Know

Environmental, Health & Safety are intertwined. Even if the audit scope does not cover H&S, such as during an ISO 14001 audit, we have an obligation to mention areas of concern, especially when the health & welfare of employees is at risk. Health and Safety is critical in the electronic recycling industry, we cannot ignore non-conformances in these areas irrespective of the audit scope. They are on our audit priority list along with the other things listed below. I hope these tips help you avoid non-conformance during your Program, R2 or ISO 14001 audits!


10 Areas of Non-Conformance

You can be sure that the auditor will check the following elements:

  1. The processes that deal with significant aspects
  2. Risk ratings prior to and after the control methods
  3. Policies and processes around focus material
  4. The controls for hazardous materials to prevent employees from exposure
  5. Records of transport management
  6. Storage of hazardous material
  7. Evidence and records of legal compliance
  8. Security of the facility
  9. Contingency and closure plans with a financial vehicle
  10. Other important areas


“Below I discuss each one briefly. To learn other common non-conformances, case studies, as well as general industry trends I invite you to Register for the Webinar to attend and ask me your questions or receive the recording and slide deck.”


1. The processes that deal with significant aspects

Significant aspects are activities that you can control within the life cycle of your products, along with their associated environmental impacts. Under R2 certification we review focus material (electronics with Mercury, Lead, Cadmium, etc.) handling, a significant aspect, and the integration of the associated processes into the risk matrix.


2. Risk ratings prior to and after the control methods

You must maintain risk ratings. Failing to do so is a non-conformance. If you use an RPN method, be sure to give the government regulated aspects the highest rating.

It is important to review the risk matrix and evaluation following a change in your operations, processes or equipment. Outdated risk matrix, a common non-conformance, occurs mostly because organizations hire a 3rd party to develop the initial matrix, but fail to review it on an ongoing basis.

Ideally, the environmental committee of your organization should develop and maintain the risk matrix and also send it for management review to identify potential changes. As auditors, we will review if these actions and evaluations were done during your management review meetings.


3. Policies and processes around focus material

During R2 audits, we review the policies and processes that cover the removal, handling, and storage of CRTs, batteries, and circuit boards. Ethylene glycol (from projection TVs, CRTs, lead-acid batteries, etc.) poses serious risks of fire. Its secondary containment is therefore crucial. We mark the lack of this storage as a non-conformance. We also check min/max levels of hazardous material storage time so you must maintain these records.


4. The controls for hazardous materials to prevent employees from exposure

We check if your MSDS (Material Safety Data Sheets) are readily available on the floor and are up-to-date. The ideal way to do this is with a software. Failing to keep this list up-to-date is also a common non-conformance.


5. Records of transport management

Under R2 certification we check if you have up-to-date records of your transporters to ensure they have valid licenses at all times and have not been involved in any accidents or incidents. If your transporter transfers the material to another transporter at any stage of the product lifecycle, it is your responsibility to ensure that that transporter too has a valid license and other necessary permits. We commonly find these records out-of-date. There are software available for this task which can make its maintenance much easier. More about that during the webinar.


6. Storage of hazardous material

Seasonal fluctuation in product supply is common. But it is the responsibility of the management to ensure that you are not storing hazardous material in an unsafe manner while you are temporarily unable to process. I have seen mountains of equipment at parking areas of many recycling facilities. This is a serious non-conformance. There are many ways deal with the extra material. I will touch upon this issue during the webinar.


7. Evidence and records of legal compliance

This is by far the most common reason of non-conformance leading to organizations losing their certifications. It is challenging to keep up with the ever-changing regulations, but there many great solutions in the market which are much less expensive than losing the certification or a receiving a government penalty. Like storage, an outdated legal registry is a serious non-conformance. I will discuss the solution to this challenge in greater depth during the webinar.


 8. Security of the facility

Security is a big issue at the time of an audit, especially with data breaches becoming common. To avoid security breach, you should require all visitors and contractors to sign-in. You should make contractors review your EH&S policies as well as have them inform you of the potential environmental aspects and risks of the equipment/materials that they bring into your plant.

We do see many opportunities for improvement in this area. For example, you can install cameras and alarm systems to secure your facility and implement policies to prevent employee theft of equipment, especially memory cards. Prevention of theft comes in many forms. You can assign security guards with metal detection equipment to monitor visitors and employees going into the facility. You can also invest in electronic keys to ensure only authorized personnel can access the facility.


9. Contingency and closure plans with a financial vehicle

During an audit, we look into the closure plan and financial vehicle to learn if it is sufficient to cover the costs of treatment of the remaining e-waste if a company goes out of business. The financial bond value is usually based on the capacity and storage levels of the site and equipment. As auditors, we review the capacity calculations to look if they have have been tampered with to reduce costs of the financial vehicle. I have caught a few organizations engaging in this very bad practice!


10. Other important areas that we check are:

Other areas we check at the time of an audit are your:

  • downstream recycler management;
  • document control;
  • personal protective equipment (PPE) of the employees; and
  • reporting and actions on incidents or near misses.


I have many horror stories from my time as a lead auditor, I hope the stories I share during the webinar will scare you into conformance! I will also discuss the best practices to overcome some of your operational challenges and bottlenecks. I invite you to register below to attend the webinar or receive the recording and slides.


Free Educational Webinar

Electronic Recycling Best Practices

Register here

Tuesday, February 20, 2018
Expert: Ronald Lepore


Ronald Lepore 
A former RQO auditor, Ronald was instrumental in the development and creation of a multi-site Canadian electronics recycling facility which included shredding and manual teardown operations. He personally implemented and deployed R2/RIOS, ISO14001, ISO9001 and OHSAS 18001 Standards in all sites.